SUBMISSION
Planning Scheme Amendment PA2025/0395
Proposed Rezoning of Lot 12719(A), Town of Nightcliff
Darwin Surf Life Saving Club
Purpose of submission
This submission objects to Planning Scheme Amendment PA2025/0395, which proposes to rezone Lot 12719(A), Town of Nightcliff from Conservation (CN) to Organised Recreation (OR).
Loss of Conservation zoning
The proposed rezoning represents a permanent reduction in statutory environmental protection on land that adjoins and is surrounded by the Casuarina Coastal Reserve. The documentation provided in support of the application does not demonstrate that this loss of Conservation zoning is necessary, justified, or in the public interest.
Current zoning and statutory protections
Lot 12719(A) is currently zoned Conservation under the NT Planning Scheme. This zoning provides the strongest available statutory protection for vegetation, habitat, and ecological function on the site. The application seeks to replace this zoning with Organised Recreation, a zone that anticipates and enables a broader range of uses and associated infrastructure. Once Conservation zoning is removed, the higher threshold for protecting vegetation and natural values is permanently lost, regardless of any statements about current intentions.
Lack of demonstrated need
The supporting documents confirm that the rezoning is not required for the ongoing operation of the Darwin Surf Life Saving Club. The Club has operated successfully for many years on its existing lot, which is already zoned Organised Recreation, while the adjoining land has remained zoned Conservation. No evidence is provided in the Statement of Effect that the current zoning framework has constrained the Surf Club’s activities or prevented it from meeting its operational needs. In the absence of demonstrated need, rezoning Conservation land cannot be justified.
Extent of rezoning beyond existing use
The rezoning is not confined to the existing built footprint of the Surf Club. The Site Aerial and Proposed Zoning maps show that Organised Recreation zoning would extend into land that is currently vegetated and zoned Conservation. The proposed zoning boundary aligns with a newly defined, enlarged lot rather than reflecting existing disturbance. This confirms that the proposal does not merely recognise existing use, but instead redefines the planning purpose of additional land.
Creation of a larger consolidated lot
The documentation also shows that the rezoning is directly linked to the creation of a new, larger consolidated lot. The proposed subdivision would combine the existing Surf Club lot with Lot 12719(A) to create a single parcel, Lot 12991, with a total area of approximately 16,270 square metres. The Site Aerial explicitly states that the existing Surf Club lease will be extinguished and replaced by a new lease area created by the application. This is a structural change to the planning and tenure framework, not an administrative adjustment. Planning decisions are made against current lots and leases, and the rezoning would establish a new baseline that expands the area assessed as appropriate for Organised Recreation uses.
Reliance on non-binding assurances
The application relies heavily on assurances that there are no current plans to further develop the land. These assurances are not binding and do not form part of the statutory planning framework. Planning decisions must be assessed on the basis of what the zoning allows, not on present intentions. Once rezoned to Organised Recreation, future proposals will be assessed under that zone’s objectives and outcomes, without the need to revisit the principle of removing Conservation protection.
Rezoning as the gatekeeper decision
The rezoning functions as the gatekeeper decision for the expanded land use outcome. If the rezoning is approved, the Conservation land is permanently converted to Organised Recreation and incorporated into an enlarged OR-zoned lot. If the rezoning is not approved, the existing arrangement remains in place, with the Surf Club continuing to operate on its current Organised Recreation lot and Lot 12719(A) retaining Conservation zoning. Refusal of the rezoning would not prevent the Surf Club from operating, but approval would irreversibly change the planning framework.
Strengthened conservation context
The conservation context of the site has strengthened in recent years. Casuarina Coastal Reserve was formally declared a park and expanded in 2024. Lot 12719(A) and the Surf Club site are surrounded by reserve land and lie near one of Darwin’s last remaining wildlife corridors. In this context, the threshold for removing Conservation zoning should be higher, not lower. The application does not adequately address cumulative impacts on reserve integrity, habitat connectivity, or long-term ecological function.
Significance of the proposed change
The proposal is framed in the supporting material as minor and administrative, yet it seeks a permanent change to statutory zoning controls. There is a clear mismatch between how the proposal is characterised and the legal effect it would have. Rezoning Conservation land to Organised Recreation is a significant planning decision with long-term consequences, and it should not proceed without compelling justification.
Conclusion
For these reasons, this submission objects to Planning Scheme Amendment PA2025/0395 and submits that Lot 12719(A) should remain zoned Conservation. Retaining Conservation zoning protects the integrity of the Casuarina Coastal Reserve, maintains appropriate statutory safeguards for vegetation and habitat, and does not impede the ongoing operation of the Darwin Surf Life Saving Club.
REFERENCES
Northern Territory Planning Scheme, Zoning Maps – Part Lot 9375, Town of Nightcliff (Current Zoning).
Northern Territory Planning Scheme, Zoning Maps – Part Lot 9375, Town of Nightcliff (Proposed Zoning).
Planning Scheme Amendment PA2025/0395, Statement of Effect, Darwin Surf Life Saving Club, October 2025.
Attachment A – Site Aerial, Part Lot 9375, Town of Nightcliff.
Attachment B – Current Site Zoning, Part Lot 9375, Town of Nightcliff.
Attachment C – Proposed Zoning, Part Lot 9375, Town of Nightcliff.
Attachment D – Proposed Subdivision Plan, Lot 12991, Town of Nightcliff.
Northern Territory Government Gazette No. G1, 5 January 2023, Proclamation under the Crown Lands Act 1992 revoking part of Reserve No. 1677.
Friends of Lee Point, Planning Notice Commentary on PA2025/0395, Proposed Rezoning of Lot 12719(A).